Segal et al v. Bitar et al

Filing 97

DECLARATION of Thomas H. Burt in Opposition re: 52 MOTION to Dismiss the Complaint under FRCP 12(b)(2) and 12(b)(6).. Document filed by Nick Hammer, Robin Hougdahl, Steve Segal, Todd Terry. (Burt, Thomas)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

STEVE SEGAL, NICK HAMMER, ROBIN
HOUGDAHL, and TODD TERRY, on
behalf of themselves and all others similarly
situated,
Case No.: ll-cv-4521

Plaintiffs,
v.

RAYMOND BITAR; NELSON BURTNICK;
FULL TILT POKER, LTD.; TILTWARE, LLC;
VANTAGE, LTD; FILCO, LTD.; KOLYMA CORP.
A.V.V.; POCKET KINGS LTD.;
POCKET KINGS CONSULTING LTD.;
RANSTON LTD.; MAIL MEDIA LTD.;
HOWARD LEDERER; PHILLIP IVEY JR.;
CHRISTOPHER FERGUSON; JOHNSON
JUANDA; JENNIFER HARMAN-TRANIELLO;
PHILLIP GORDON; ERICK LINDGREN; ERIK
SEIDEL; ANDREW BLOCH; MIKE MATUSOW;
GUS HANSEN; ALLEN CUNNINGHAM; PATRIK
ANTONIUS and JOHN DOES 1-100,
Defendants.

I, THOMAS H. BURT, Esq., hereby declare under penalty of perjury that the following
is true and correct to the best of my knowledge:
1.

I am a member of the law firm of Wolf Haldenstein Adler Freeman & Herz LLP,

and am admitted to practice before this Court.

I have personal knowledge of the facts stated

below.
2.

This firm is counsel to Steve Segal, Nick Hammer, Robin Hougdahl, and Todd

Terry ("Plaintiffs").

I submit this Declaration to supplement the information in Plaintiffs'

Opposition to Defendants' Motion to Dismiss and the Declaration of Thomas II. Burt filed on
September 16, 2011, pertaining specifically to Defendant Johnson Juanda ("J uanda").

Defendant Johnson Juanda Directly Gambled with New Yorkers Through the Full Tilt Site

3.
Defendant

Plaintiffs' independent research has revealed specific instances in which
Juanda

participated

in

Full

Tilt

online

poker

rooms

(all

hosted

on

www.fulltiltpoker.com) with New York residents.
4.

Team Full Tilt pro player and Defendant Juanda has played hands of online poker

against New Yorkers on numerous occasions.
5.

Defendant Juanda played hands of online poker against New Yorker Phil Galfond

(who used the Full Tilt usemame "OMGClayAiken") on September 11, October 10, October 30,
October 31 and December 28,2008.
6.

Defendant Juanda played hands of online poker against New Yorker Jason

Rosenkrantz (who used the Full Tilt usemame "pr l nnyraid") on November 18,2008.
7.

Defendant Juanda played hands of online poker against New Yorker Emil Patel

(who used the Full Tilt usemame "whitelime") on June 1, July 23 and October 13,2008.
8.

Defendant Juanda played hands of online poker against New Yorker Ariel

Schneller (who used the Full Tilt usemame "DaEvils") on June 27, July 16, July 27, July 28 and
August 3, 2008.
9.

Defendant Juanda played hands of online poker against New Yorker Daniel Stem

(who used the Full Tilt usemame "ansky451") on July 1 and July 22, 2008.

Dated: October 7, 2011

670033

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